Featured Issues

Featured Issue: Immigration Detention and Alternatives to Detention

3/14/25 AILA Doc. No. 24121300. Detention & Bond, Removal & Relief

Update: On March 14, 2025, AILA released a statement in response to the Trump Administration resuming the practice of detaining families pending their court proceedings in the detention facility in Karnes County, TX, and indicating its plans to use a second facility in Dilley, TX, for family detention.

AILA calls on Congress to significantly reduce and phase out the use of immigration detention for immigration enforcement purposes. Detention is costly, leads to inefficiencies in processing cases, and has a long track record of human rights abuses. Community-based case management services and legal representation is more humane and should be offered to noncitizens to support their compliance of immigration obligations.
 


By the Numbers

  • Book Outs/Books In: The Office of Homeland Security Statistics provides data on the number of migrants who are released from CBP custody to proceed with removal cases, transfers to ICE detention, and transfers to Health & Human Services (HHS). It also provides initial book-in data on ICE detention.
  • Detention: For FY2024, Congress has provided funding to detain a daily average of 41,500 noncitizens at a cost of approximately $3.4 billion. During FY2023, Congress provided funding to detain a daily average of 34,000 noncitizens at a cost of approximately $2.9 billion. A December 2024 ICE memo in response to Congressional requests for information noted that increasing detention capacity by more than 60,000 beds will require a funding increase of approximately $3.2 billion dollars.
  • Current Population: Per ICE, on December 8, 2024, there were 39,062 people in custody and on January 22, 2025, there were 39,703. For future data, see bi-weekly data posted on the ICE website under “Fiscal Year 2025 statistics” here.
  • Daily Costs: Projected average daily costs of detaining an adult noncitizen: $164.65. The actual cost of detaining a noncitizen varies based on geographic region, length of detention, facility type, etc. A recent ICE memo in response to the costs of expanding detention noted that they expect a 5% inflationary increase from FY2024 enacted bed costs.
  • Deaths at Adult Detention Centers - AILA supplies a continually updated list of ICE press releases announcing deaths in adult immigration detention. Note: there can be delays in ICE’s reporting of deaths and there have been instances of seriously ill individuals released from ICE custody, whose deaths are not included in this list.
  • ICE Alternatives to Detention: For FY2024, Congress provided approximately $470 million in funding for ICE’s Alternatives to Detention (ADT) program. This is an increase from approximately $443 million in FY2023 in which 194,427 people were enrolled.
  • Daily Costs of ICE ATD: Average daily cost for participants enrolled in ICE’s Intensive Appearance Supervision Program (ISAP): $8.00
  • Community-Based Case Management: The FEMA/CRCL Case Management Pilot Program (CMPP), also known as the “Alternatives to Detention Grant Program,” received $15 million in continued funding for FY2024. Prior to January 20, 2025, it was operating in five cities.
  • Average daily cost of providing case management for individual family members by a community-based organization (2018 pilot): $14.05
  • Legal Representation: There is no right to a government-provided attorney in immigration court and 70 percent of detained persons face proceedings without counsel. There is a pilot program that serves adult individuals with mental disabilities. Congress did not provide any funding for adult legal representation for FY2024.

 


 

AILA’s Recommendations to Congress

  1. Reduce detention funding to at least 25,000 average daily population or less.
  2. Explicitly prohibit detention funding from being used to detain families and children in custodial settings.
  3. Provide continued funding community-based case management programs outside of ICE such as the Case Management Pilot Program (CMPP) operated by the Federal Emergency Management Agency (FEMA) and the Office for Civil Rights and Civil Liberties (CRCL)
  4. Conduct robust oversight of past congressional appropriations transparency requirements and continue to require ICE to disclose and publish information relating to detention contracts, inspection process and reports, detention data, and policies for the alternatives to detention program.

Background

Created in 2002, Immigration & Customs Enforcement (ICE) has over 22,000 full-time employees, with a total annual budget of more than $9 billion. The agency has three core operational directorates: Enforcement and Removal Operations (ERO), Homeland Security Investigations (HSI), and the Office of the Principal Legal Advisor (OPLA). Housed within the Department of Homeland Security, ICE joins Customs & Border Protection (CBP) in making up the nation’s largest police force.

Immigration enforcement, including taking noncitizens into custody, is the largest single area of responsibility for ICE. ICE detains noncitizens arrested from the interior of the country and those transferred from the border. Twenty-years ago, the average daily population of detained immigrants was approximately 7,000. During the first Trump Administration, it reached a height of 50,000 average daily population. Regardless of the circumstances of their first encounter with authorities, noncitizens are detained across America in a sprawling network of private and public detention facilities. Most of these facilities operate through contracts between ICE (or, less commonly, the U.S. Marshals Service) and localities for the purposes of detaining noncitizens. In some cases, localities later sub-contract services for operating detention facilities to private prison companies. In other instances, localities reserve space in local, county, or state jails and prisons for the purposes of detaining immigrants. In all cases, localities are financially incentivized to detain individuals to increase profit margins from contracts. One key part of the financial equation is the use of noncitizens to clean and maintain facilities in exchange for $1 a day.

Immigration detention facilities, regardless of the type of contracts, have been the sites of serious and repeated allegations of abuse, including allegations of sexual assault, violations of religious freedom, medical neglect, and the punitive use of solitary confinement. In 2020, the U.S. had the highest number of deaths in ICE adult detention since 2005. Several deaths in custody have been found to have been preventable. Conditions in ICE custody have been described as “barbaric” and “negligent” by DHS experts.

Civil immigration detention works mainly to facilitate deportation. While ICE has the authority to allow most noncitizens to continue with their removal cases on the outside of custody, it often defaults to detention based on alleged “flight risk or threat to public safety.” The vagueness of these concepts frequently works against the liberty interests of noncitizens and there is generally a lack of uniformity when it comes to these discretionary releases. Only a certain portion of the overall noncitizen population must be detained under “mandatory detention” laws and even those individuals may be released based on certain exceptions.

Lastly, because immigration detention is considered “civil,” indigent noncitizens are not generally provided counsel. As a result, representation rates for noncitizens in detention are as low as 14% and directly correlate with the ability to secure release or long-term protection.

 

Reports and Briefings

Government Reports

Legislative and Administrative Advocacy

Browse the Featured Issue: Immigration Detention and Alternatives to Detention collection
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Cases & Decisions, Federal Court Cases

District Court Orders Immigration Bond Companies to Pay Redress and Civil Money Penalties of More Than $360 Million

The district court granted plaintiffs’ requested remedies in full, including injunctive relief, redress to consumers in the amount of $230 million, and civil money penalties in the amount of $111 million. (Consumer Financial Protection Bureau, et al. v. Nexus Services, Inc., et al., 3/31/24)

3/31/24 AILA Doc. No. 24040372. Detention & Bond, Removal & Relief
Practice Resources

AILA Key Takeaways from 2024 BIA Spring Conference Panel

On March 22, 2024, AILA hosted an open forum at the 2024 Spring Conference with the BIA. The EOIR National Committee provides the following key takeaways.

3/22/24 AILA Doc. No. 24050107. Detention & Bond, Removal & Relief
Practice Resources

Practice Alert: Padilla v. ICE and Delays in Credible Fear Interviews

AILA shares an updated practice alert regarding the Padilla v. ICE settlement. This practice alert includes more detailed information on contacting class counsel regarding potential violations of the settlement in individual cases, as well as the current status of the litigation.

3/20/24 AILA Doc. No. 24040871. Asylum, Detention & Bond, Removal & Relief
Agency Memos & Announcements

OIDO Invitation to March Roundtable Discussions

The Office of the Immigration Detention Ombudsman will hold two roundtable discussions in March to collect feedback. On March 14, it will hold a MyOIDO feedback webinar and on March 21, it will hold a legal access webinar. Notice includes registration information.

3/11/24 AILA Doc. No. 24030801. Detention & Bond, Removal & Relief
AILA Public Statements, Correspondence

AILA and Partners Send Letter Urging End to Solitary Confinement in ICE Detention

AILA and partners sent a letter to the White House and DHS urging an immediate and public commitment to ending solitary confinement in ICE detention.

2/29/24 AILA Doc. No. 24030502. Detention & Bond, Removal & Relief
AILA Blog

The Mandatory Detention of Unlawful Entrants Seeking Asylum in the United States and the Due Process Protection

AILA Law Journal author Jim Nzoguma Mayua shares more about his article in the Fall 2023 edition of the journal, in which he discusses the legal uncertainty stemming from Supreme Court rulings denying asylum seekers due process protection.

DOJ/EOIR Cases

BIA Finds New Evidence Showed Respondent Was Detained Pursuant to INA §236(a) and Was Thus Entitled to Bond Hearing

Unpublished BIA decision holds that the respondent who claimed fear of persecution and who had not received a credible fear interview was entitled to a bond hearing pursuant to INA §236 based on new evidence indicating that she was in removal proceedings under INA §240. (Matter of –, 1/30/24)

1/30/24 AILA Doc. No. 24021600. Detention & Bond, Expedited Removal, Removal & Relief
Congressional Updates

AILA Advocacy Toolkit for Congressional Border Deal

AILA provides members with a summary of border supplemental funding proposals that would trade funding for Ukraine and other allies for dramatic changes to U.S. asylum and detention laws. This toolkit includes Senate office contact information, template emails, and a template call script.

Federal Agencies, Practice Resources

Practice Alert: Access to Counsel in ICE Detention

This practice alert serves to update AILA members on the recent expansion of the Virtual Attorney Visitation (VAV) program, to share resources for communicating with detained clients, and how to escalate access to counsel issues with ICE.

1/19/24 AILA Doc. No. 22092201. Detention & Bond, Removal & Relief
DOJ/EOIR Cases

BIA Holds That Collateral Estoppel Does Not Apply to Respondent’s Bond Proceedings

The BIA held that a respondent’s release from federal pretrial criminal custody does not preclude an IJ from denying a respondent’s request for release from immigration detention under INA §236(a). Matter of Panin, 28 I&N Dec. 771 (BIA 2024)

1/11/24 AILA Doc. No. 24011201. Detention & Bond
Cases & Decisions, Federal Court Cases

ICE Agrees to Post Its Bond Processing Policies Online in FOIA Lawsuit Settlement

A federal district court in California approved a settlement in which ICE agreed to post its bond processing policies online to settle a Freedom of Information Act (FOIA) lawsuit filed by bond-funding groups in December 2022. (National Bail Fund Network, et al. v. ICE, et al., 1/11/24)

1/11/24 AILA Doc. No. 24011707. Detention & Bond, Removal & Relief
Chapter Documents

Michigan Chapter: ICE ERO Contact List (1/9/24)

ICE Enforcement and Removal Operations (ERO) Detroit contact list as of 1/9/24 – detained and non-detained.

1/9/24 AILA Doc. No. 24011606. Detention & Bond, Removal & Relief
Federal Agencies, FR Regulations & Notices

Department of the Treasury Notice on Interest Rate for Immigration Bonds

Department of the Treasury notice that for the period beginning 1/1/24 and ending 3/31/24, the U.S. Immigration and Customs Enforcement Immigration Bond interest rate is 3 per centum per annum. (89 FR 986, 1/8/24)

1/8/24 AILA Doc. No. 24010809. Detention & Bond, Removal & Relief
Cases & Decisions, Federal Court Cases

Resources Related to Case Challenging Credible Fear Interview and Bond Hearing Delays (Padilla v. ICE)

The U.S. District Court for the Western District of Washington issued an order granting the parties’ stipulated motion to dismiss Count IV of the complaint and granting final approval of the class action settlement for the Credible Fear Class. (Padilla v. ICE, 1/5/24)

1/5/24 AILA Doc. No. 18062734. Asylum, Detention & Bond, Removal & Relief
Agency Memos & Announcements

ICE Provides its National Detainee Handbook

The ICE National Detainee Handbook is provided to individuals being housed in ICE-operated or contracted detention facilities. It is currently available in 15 languages.

1/1/24 AILA Doc. No. 24122431. Detention & Bond, Removal & Relief
Immigration News

AILA Law Journal, Vol. 5, Number 2, October 2023

The October 2023 edition of the AILA Law Journal is now available.

12/7/23 AILA Doc. No. 23120700. Adjustment of Status, Asylum, Detention & Bond, Removal & Relief
AILA Public Statements, Correspondence

AILA, AIC, and ACLU Lead Sign-On Letter Detailing Continued Barriers to Attorney Access in ICE Immigration Detention Facilities

AILA, AIC, and the ACLU lead over 80 organizations in a letter to ICE detailing continued barriers to attorney access in immigration detention facilities and provide recommendations on how to better facilitate critical communications between counsel and detained individuals.

11/21/23 AILA Doc. No. 23112102. Detention & Bond, Removal & Relief
Practice Resources

Practice Pointer: Continued Detention of Non-Citizens Who Won Immigration Relief

AILA provides a practice pointer on ICE’s continued detention of clients’ post-grant of relief, summary of litigation efforts, and provides guidance to attorneys with clients in this situation. Special thanks to the Capital Area Immigrants’ Rights Coalition.

10/25/23 AILA Doc. No. 23102500. Detention & Bond
Practice Resources

Practice Alert: Venezuela TPS and Removal Flights Resume

AILA’s ICE Committee provides a practice alert on the resumption of removal flights to Venezuela, detained TPS-eligible clients, and tips on screening for post-order removal relief.

AILA Public Statements

AILA Welcomes Agreement by Biden Administration to Protect Families from Inhumane Policy Instituted Under Trump

AILA welcomed the DHS announcement that a proposed agreement has been struck that will protect families from the inhumane practice of family separation instituted under then-President Trump; the policy was a “gross injustice” that caused “heartbreaking turmoil.”

10/16/23 AILA Doc. No. 23101610. Detention & Bond, Removal & Relief
Practice Resources

Practice Advisory: Representing Detained Clients in the Virtual Landscape

AILA and the CAIR Coalition provide a practice advisory that focuses on the challenges unique to the detention context and how best to address some of the key issues to effectively providing remote representation to detained noncitizens.

10/10/23 AILA Doc. No. 23101001. Detention & Bond, Removal & Relief
FR Regulations & Notices

Department of the Treasury Notice on Interest Rate for Immigration Bonds

Department of the Treasury notice that for the period beginning 10/1/23 and ending 12/31/23, the U.S. Immigration and Customs Enforcement Immigration Bond interest rate is 3 per centum per annum. (88 FR 69683, 10/6/23)

10/6/23 AILA Doc. No. 23112235. Detention & Bond
Federal Agencies, Agency Memos & Announcements

White House Announces New Actions to Increase Border Enforcement and Accelerate Processing for Work Authorizations

The White House announced new measures to enhance border security, including an expansion of FERM, increasing DHS holding and processing capacity, accelerated processing for EADs filed by parolees who scheduled an appointment through CBP One, and more.

Cases & Decisions, Federal Court Cases

CA4 Finds IJ Erred by Failing to Inform Petitioner of Bond Amount and Deadline Before Granting Voluntary Departure

The court held that the BIA erred in concluding that the IJ was not required to advise petitioner of the bond requirement before granting voluntary departure, and found that it was insufficient for the IJ to provide the required advisals in the order itself. (Solis-Flores v. Garland, 9/11/23)

Federal Agencies, Practice Resources

Practice Alert: Office of The Detention Ombudsman Case Intake Process

AILA provides a summary of the Detention Ombudsman Case Intake Process and written responses to questions posed during an open forum session with the Office of the Immigration Detention Ombudsman (OIDO) at the 2023 AILA Annual Conference.

9/7/23 AILA Doc. No. 22051000. Detention & Bond, Removal & Relief